It seems that new EU’s energy label exempts most of the secondary mobile market

From 20 June 2025, all new smartphones sold in the European Union, whether manufactured locally or imported, must carry a newly designed EU energy label. This measure, developed under the EU’s Circular Economy Action Plan and Green Deal, aims to reduce e-waste and promote sustainable design by improving product transparency around energy use, durability, and repairability. It looks that used and refurbished smartphones are, for now, largely exempt from the energy label requirement.

While originally developed for fridges and TVs, the label now applies to smartphones and tablets. It offers ratings for energy efficiency (A to G), battery endurance (in hours), water and dust protection (IP rating), drop resistance, and a repairability index.

Ecodesign rules complement the label

Alongside the label, the European Commission also approved a package of ecodesign requirements. These include mandatory support for software updates for up to five years, battery durability of at least 500 full charge cycles with 83% capacity retention, and spare parts availability for up to seven years. OEMs will also need to provide repair manuals and make specialized tools available to professional repairers.

Refurbished phones largely exempt

However, there is a grey area. If a device is substantially rebuilt, given a new model number, or marketed as “like new,” it may be considered “new” under EU law. In such cases, the refurbisher must meet all compliance obligations, energy testing, product registration in EPREL, and correct labelling.

Repair rules support the refurb ecosystem

Even if they are not legally bound to the new rules, refurbishers stand to benefit from the ecodesign measures. Easier access to OEM parts, longer software support, and standardized repair documentation could reduce costs and improve operational efficiency. These improvements can enhance both the profitability and environmental impact of the refurbishment business.

Strategic implications for the secondary market

Companies in the refurbished smartphone sector need to tread carefully. There is compliance risk if they blur the line between used and new. On the other hand, greater transparency around durability and battery quality offers a chance to strengthen consumer trust. While not required to display the label, some refurbishers may opt to voluntarily share performance data to boost credibility.